Frequently Asked Questions
Q: WHO MUST DISCLOSE?
A. Any individual acting as a “project director, principal investigator or any other person, regardless of title or position, who is responsible for any part of the design, conduct, or reporting of research” is an investigator and must satisfy the disclosure requirements.
Q: WHO IS AN INVESTIGATOR?
A. Any University employee, regardless of title or position, who has the ability to make independent decisions related to the design, conduct, or reporting of University research. This does not include individuals who perform only incidental or isolated tasks related to a University research project. Since title and position are not indications of who is an "investigator," it is possible for students and post-docs to meet this definition. Please note, in nearly all situations when an individual is listed as senior or key personnel on a proposal or award they are considered an investigator for purposes of submitting a financial disclosure statement.
Q: DO POST-DOCS AND GRADUATE STUDENTS NEED TO DISCLOSE?
A. Yes, if they meet the definition of investigator above.
Q: WHAT ARE SOME EXAMPLES OF RESEARCH PROJECTS THAT WOULD BE RELATED TO AN SFI?
A. Some examples include:
- You are a paid consultant to COI, Inc., which also subcontracts a portion of a research project to your lab at the University.
- You are a paid consultant to COI, Inc., and you subcontract a portion of your research project back to COI, Inc.
- You are a paid speaker for COI, Inc., and also the PI of a research project funded by COI, Inc.
- COI, Inc. has paid for your travel. You also conduct research at the University that is likely to develop intellectual property that you know would be of interest to COI, Inc.
- You own stock in COI, Inc. and COI, Inc. provides cost-sharing on an award in your lab at Kanas State University.
Q: IF I DO NOT HAVE ANY SIGNIFICANT FINANCIAL INTEREST, DO I STILL NEED TO SUBMIT ANYTHING?
A. Yes. Even if you do not have an SFI to disclose, you must still complete the Supplemental Declaration of Financial Conflict of Interest and return to the University Research Compliance Office at FFI@ksu.edu.
Q: WHAT ABOUT A FOREIGN GOVERNMENT AGENCY?
A. Yes. Honoraria or payments from foreign institutions MUST be disclosed.
Q: DOES INCOME FROM A FOREIGN INSTITUTION OF HIGHER EDUCATION OR A FOREIGN GOVERNMENT NEED TO BE DISCLOSED?
A. Yes. Foreign institutions and governments are not excluded from SFI, and any income OR travel from one must be disclosed.
Q: DOES INCOME FROM A NON-PROFIT ORGANIZATION NEED TO BE DISCLOSED?
A. Yes. Federal regulations require the disclosure of income and travel from non-profit organizations.
Q: DO HONORARIA OR TRAVEL FROM A PROFESSIONAL SOCIETY NEED TO BE DISCLOSED?
A. Yes. Professional societies are non-profit organizations, and travel and income from them is required to be disclosed.
Q: WHEN DO I NEED TO DISCLOSE OR UPDATE MY DISCLOSURE?
A. Investigators are required to disclose their SFI:
(a) within 30 days of the investigator’s initial employment date;
(b) annually;
(c) within 30 days after acquiring a new SFI requiring disclosure; and
(d) for those Investigators participating in Public Health Service (PHS)-funded research, not later than the application date for PHS-funded research, except that an investigator who will be participating in an ongoing PHS-funded research project must submit a Financial Disclosure Statement within 30 days of the investigator’s initial employment date.
Q: WHAT IF I INADVERTENTLY FAIL TO DISCLOSE MY SIGNIFICANT FINANCIAL INTEREST (SFI)?
A. You must disclose the SFI immediately. The disclosure will be reviewed to determine if a financial conflict of interest exists, and if so, an interim management plan will be implemented to ensure the objectivity of the research going forward.
Q: DOES TRAVEL NEED TO BE DISCLOSED?
A. Yes. The revised federal regulation does not provide a minimum threshold for the disclosure of reimbursed or sponsored travel. The occurrence of any reimbursed or sponsored travel related to the investigator’s institutional responsibilities must be disclosed, UNLESS the reimbursed or sponsored travel is by a federal, state, or local government agency, or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
Q: WHEN DO I NEED TO UPDATE MY REIMBURSED OR SPONSORED TRAVEL - BEFORE THE TRIP OR AFTER?
A. All investigators must update their disclosure with information regarding travel within 30 days of the end of the trip.
Q: WHAT TYPES OF SPONSORED OR REIMBURSED TRAVEL DO NOT NEED TO BE DISCLOSED?
A. You do not need to disclose travel that is sponsored or reimbursed by a federal, state, or local government agency, or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
Q: DOES TRAVEL PAID BY A PROFESSIONAL SOCIETY NEED TO BE DISCLOSED?
A. Yes. Professional societies are non-profit organizations and travel and income from them is required to be disclosed.
